Congressional Bank

Paycheck Protection Loan Forgiveness (as of 9/22/20)

Congressional Bank has developed an online portal to accept forgiveness applications, similar to how applications for PPP loans were accepted. Instructions for how to access the portal are here. Only users who signed the PPP note will initially be given access to the forgiveness portal. If you need additional users to have access, please email CARES@congressionalbank.com.

Our online application will fill out a PDF application for you, ensuring the correct calculations are made. We will also ask for supporting documentation for the expenses listed on your forgiveness application. You will then be asked to sign the completed form so that we can submit the final version to the SBA for their review.

Per SBA regulations, banks have 60 days to review forgiveness requests and the SBA then has 90 additional days to provide a final decision. Borrowers will be notified of progress as their application moves through different stages.

If you have questions on how to provide the data required for a PPP forgiveness application, please see the FAQs listed below.

Common PPP Forgiveness Questions

Where Can I Find the Forgiveness Application forms?
  • Congressional’s PPP Forgiveness Portal will fill out the required form for you, but if you would like to see the forms for what you will be asked, see below
  • The updated PPP forgiveness application is here and the associated instructions are here.
  • The SBA also has an “EZ” version of the forgiveness application that can be used by:
    • All self-employed individuals, sole proprietors, independent contractors who did not include employee salaries in their PPP application
    • Borrowers who have not reduced salaries / hourly wages by more than 25% for any employee and have not reduced headcount during the forgiveness period.
    • Borrowers who have not reduced salaries / hourly wages by more than 25% for any employee and certify they are unable to operate during the forgiveness period at the same level of business activity as before February 15, 2020 due to safety / health restrictions or guidance related to COVID-19.
    • This shorter form is here and the associated instructions are here.
Are There Resources Available to Help Borrowers Understand and Complete the Application Forms?
  • The SBA’s rules on forgiveness guidelines and requirements are here.
  • The SBA has released an FAQ with answers to common questions on the forgiveness process here.
  • The American Institute of CPAs has a page of FAQs (here) for PPP loans, which can provide help for borrowers in answering forgiveness questions.
  • You can always email CARES@congressionalbank.com for help, but if you’d prefer to talk to an individual advisor about a complex situation, you can receive guidance on your PPP loan forgiveness application from Upside Financial, who has experience in navigating PPP and the forgiveness process. Upside Financial charges a fee for its services. To find out how to get started, visit upsidefinancial.com/congressional.
    • Please note that this link will take you away from the Congressional Bank website. Congressional Bank is not affiliated with nor financially compensated by Upside Financial.
When Does My Covered Period Begin, and How Long Does It Last?

The Covered Period begins on the date Congressional Bank deposited PPP proceeds into your account. Borrowers may also choose an Alternative Covered Period that begins the first day of the borrower’s pay period following their loan disbursement date. Note that this Alternative Covered Period only applies to payroll costs, and all nonpayroll costs must use the standard Covered period.

Borrowers who received funds prior to June 5, 2020 can elect an 8-week or 24-week period, while borrowers receiving funds on or after June 5, 2020 will have a 24-week covered period.

What Costs Are Eligible for Forgiveness?

Expenses eligible for forgiveness include payroll costs and healthcare benefits, plus payments for mortgage interest, rent, utilities and interest on debt incurred prior to February 15, 2020. Prepaid expenses that are not incurred during the forgiveness period (such as paying rent in advance) are not eligible for forgiveness. Payroll costs must account for at least 60% of the expenses listed as forgiveness-eligible on the application or the forgiveness amount will be proportionally reduced.

Payroll costs can include all forms of cash compensation paid to employees, including employer-paid healthcare expenses, employer retirement contributions, tips, commissions, bonuses and hazard pay. The forgivable cash compensation per employee is capped at $100,000 on an annualized basis.

Generally speaking, costs incurred prior to the Covered Period but paid during the Covered Period, or incurred during the Covered Period and paid after the Covered Period, can be included as forgivable expenses if they were paid on or before the next regular payroll or billing period.

What Other Supporting Documentation Will Congressional Bank Require for My PPP Forgiveness Application?

Per SBA regulations, we are required to collect documentation supporting all payroll and nonpayroll costs listed on the PPP forgiveness application. Per SBA guidance, this support should come in the form of third-party reports, statements or invoices.

For payroll, this should take the form of payroll reports or other benefit statements.

For non-payroll costs such as rent, this must include evidence of the obligation (lease agreement or mortgage agreement) as well as payment during the Covered Period.

When Can I Apply for Forgiveness?

A borrower can submit a forgiveness request at any point up until the loan maturity, however payments on the loan will begin 10 months after the covered period ends.

A borrower may submit a forgiveness request before the end of the covered period but must consider the full effect of any salary / wage decreases as if the full covered period had elapsed.

When Are Payments Due on My PPP Loan?

Regardless of what your loan document may say, Congressional plans on following current SBA guidance, which says that as long as a borrower submits a loan forgiveness application within 10 months of the completion of the Covered Period, the borrower is not required to make any payments until the forgiven amount is submitted to the lender by the SBA.

If, at that point, there is still a remaining loan balance, regular payments will begin on a schedule provided to you by Congressional at that time.

For Independent Contractors (and Other PPP Borrowers Who Used a 2019 Schedule C for PPP Loan Amount) Without True “Payroll”, How Do I Provide Supporting Payroll Documentation?

If you applied for a PPP loan from Congressional using your 2019 Schedule C, this document by itself can provide support for payroll forgiveness. You are eligible for forgiveness up to 2.5/12 of your 2019 Schedule C net profit (line 31). Please provide your 2019 Schedule C in the forgiveness process to expedite the review.

I Cannot Operate Normally Due to COVID-19 Restrictions, What Can I Do?

Borrowers can certify on the forgiveness application that they cannot operate normally and will not be penalized for having lower average FTEs than the reference period. Payroll costs must still be incurred and total at least 60% of the forgiveness amount to not be reduced by the 60% payroll restriction, but the inability to fully staff a business will not reduce forgiveness.